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AAUDE Data Sharing Guidelines and Confidentiality Rules

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<strong>AAUDE</strong> <strong>Data</strong> <strong>Sharing</strong> <strong>Guidelines</strong> <strong>and</strong> <strong>Confidentiality</strong> <strong>Rules</strong><br />

9/29/2011<br />

General Introduction<br />

The purpose of the Association of American Universities <strong>Data</strong> Exchange (<strong>AAUDE</strong>) is to<br />

facilitate <strong>and</strong> coordinate the gathering <strong>and</strong> exchange of data <strong>and</strong> information primarily for <strong>and</strong><br />

among its members, <strong>and</strong> to continually enhance efficiency <strong>and</strong> data consistency in collecting <strong>and</strong><br />

exchanging data. <strong>AAUDE</strong> values free exchange of timely <strong>and</strong> accurate information while fully<br />

appreciating the privacy <strong>and</strong> confidentiality requirements involved.<br />

Certain data exchange items are clearly public in nature for which unimpeded use <strong>and</strong> display of<br />

their data are appropriate <strong>and</strong> should be encouraged. Other exchange items contain sensitive<br />

information that exchange participants consider as confidential, in which case the privacy of<br />

individuals <strong>and</strong> the confidentiality of member institutions need to be protected.<br />

To encourage maximum participation in <strong>AAUDE</strong> data exchanges among member institutions,<br />

participants must have confidence that they can rely on <strong>AAUDE</strong> representatives to follow<br />

established data-sharing guidelines <strong>and</strong> rules during presentation <strong>and</strong> dissemination of<br />

confidential data.<br />

Thus, the overarching goal of this policy is to strike a balance between data access <strong>and</strong><br />

confidentiality.<br />

Responsibility for Observing <strong>Guidelines</strong> <strong>and</strong> <strong>Rules</strong><br />

By participating in <strong>AAUDE</strong>, each member institution agrees to observe confidentiality of all data<br />

so designated <strong>and</strong> to abide by all data-sharing guidelines <strong>and</strong> rules, including special rules for<br />

individual exchange items.<br />

Responsibility for developing <strong>and</strong> ensuring observance of data-sharing guidelines <strong>and</strong> policies is<br />

vested with the <strong>AAUDE</strong> Council, the governing body established to develop <strong>and</strong> implement a<br />

strategic plan <strong>and</strong> coordinate the association’s activities.<br />

Primary responsibility for adhering to data-sharing guidelines <strong>and</strong> rules, <strong>and</strong> observance of data<br />

confidentiality at the institutional membership level is vested with the institutional<br />

representatives, especially the primary representative. Stated differently, the primary<br />

representative of a member institution is ultimately responsible for ensuring appropriate use <strong>and</strong><br />

release of information by all people who access <strong>AAUDE</strong> data at his/her institution.<br />

Further, each representative, whether primary or alternate, <strong>and</strong> each data user seeking permission<br />

to access <strong>AAUDE</strong> data sources, including its data warehouse, shall be required to sign a<br />

Memor<strong>and</strong>um of Underst<strong>and</strong>ing (MOU).<br />

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General <strong>Data</strong> <strong>Sharing</strong> <strong>Guidelines</strong> <strong>and</strong> <strong>Rules</strong><br />

“No Submission, No Access” Principle. Access to an exchange item is intended for those<br />

member institutions that participate in exchanging data for that item. Institutions that do not<br />

provide their own data shall refrain from using any such data. Non-participants in an exchange<br />

item may be denied access.<br />

Institutional Legal <strong>and</strong> Cultural Difference. The legal <strong>and</strong> cultural frameworks that affect<br />

confidentiality of information vary by type of institution. For example, data sharing among<br />

public universities tends to be less restrictive than among private universities. Users of <strong>AAUDE</strong><br />

data sources should be cognizant of such differences <strong>and</strong> use data accordingly.<br />

Use of <strong>Data</strong> with Small Number of Cases. Individual identification is possible when a small<br />

number of individuals share a single characteristic such as gender, race/ethnicity, disability<br />

status, etc., thus breaching confidentiality. In order to prevent tracing of the identity of<br />

individuals, <strong>AAUDE</strong> data users should not report any variable in which there are fewer than five<br />

individuals in a cell.<br />

<strong>Data</strong> Quality. To ensure data quality, <strong>AAUDE</strong> data users are expected to perform the<br />

professionally required validity, consistency, <strong>and</strong> reasonability checks before using information.<br />

Exchange Items with External <strong>Rules</strong>. If an exchange item is governed by external rules (e.g.,<br />

NSSE), those rules should be explicitly referenced on the exchange item webpage.<br />

Purpose of <strong>Data</strong> <strong>and</strong> Intended Audiences. The purpose of confidential data exchanged by<br />

<strong>AAUDE</strong> is to assist in internal decision making at our universities. Some presentations of data<br />

may be shared with the campus at large or even on public websites, but confidential data should<br />

not be reported to an external requester even if adequately summarized.<br />

Categories of Exchange Items by Level of <strong>Confidentiality</strong><br />

The degree of confidentiality of the many kinds of data shared by <strong>AAUDE</strong> varies substantially.<br />

To balance the need for free, unimpeded use of data with the need for observing confidentiality<br />

of data, it makes sense to group exchange items into categories <strong>and</strong> establish data-sharing<br />

guidelines <strong>and</strong> rules appropriate for each category. The data-sharing guidelines <strong>and</strong> rules are<br />

designed to minimize the potential risk of public disclosure of sensitive data. The four categories<br />

of exchange items are:<br />

1. Publicly reported data<br />

2. Ad hoc/special requests<br />

3. Confidential exchange items<br />

4. Confidential items requiring special rules<br />

Each existing <strong>AAUDE</strong> exchange item is placed in one of these four categories depending on the<br />

level of confidentiality involved. As a new exchange item is added, the <strong>AAUDE</strong> Council will<br />

evaluate <strong>and</strong> assign it to the appropriate category.<br />

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1. Publicly Reported <strong>Data</strong><br />

The exchange items in this category are publicly available. They include: periodic surveys<br />

conducted by the Department of Education’s National Center for Education Statistics (NCES)<br />

through the IPEDS system, surveys by the National Science Foundation (NSF) <strong>and</strong> other data<br />

collection agencies such as the AAUP. The publicly reported exchange items are listed in the<br />

attachment to this report.*<br />

These exchange items are not subject to <strong>AAUDE</strong>’s specific data-sharing guidelines <strong>and</strong><br />

confidentiality rules. However, data users are expected to: (a) observe the collection agency’s<br />

confidentiality rules <strong>and</strong> cautionary notes, <strong>and</strong> (b) not publish any of these data before they are<br />

publicly released by the collection agency.<br />

2. Ad Hoc/Special Requests<br />

Member institutions regularly send various inquiries <strong>and</strong> special requests to Exchange<br />

participants. Such inquiries <strong>and</strong> special requests are not deemed confidential unless specified by<br />

the inquiring or the responding institution.<br />

An institution that conducts an inquiry or a special request is expected to share appropriate<br />

summaries of the results of the inquiry or special request with the Exchange group as soon as it<br />

compiles the responses.<br />

Such a summary should not be issued with both institution names <strong>and</strong> their corresponding<br />

<strong>AAUDE</strong> codes in order to restrict distribution of these codes.<br />

3. Confidential Exchange Items<br />

This category of exchange items contains sensitive information that Exchange participants have<br />

defined as confidential. Thus, establishment <strong>and</strong> observance of data-sharing guidelines <strong>and</strong> rules<br />

are essential. The confidential exchange items are listed in the attachment to this report.*<br />

Users should observe the following guidelines when using data from confidential exchange<br />

items:<br />

a) Use aggregated data (such as mean, median, range) in reports when appropriate <strong>and</strong><br />

possible.<br />

b) Use only codes (but not the <strong>AAUDE</strong> code), <strong>and</strong> not names of institutions when reporting<br />

individual institutional data.<br />

c) Identify an institution as a member of a known category of institutions comprising a<br />

given set of confidential data in a report (for example, public research university, private<br />

research university, l<strong>and</strong>-grant university, etc.).<br />

d) An institution may be identified by name or any publicly available <strong>and</strong> recognizable code<br />

(e.g. FICE code) when reporting institution-specific data only if prior approval has been<br />

obtained from that institution.<br />

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A brief statement acknowledging the source of data <strong>and</strong> any restrictions associated with the<br />

data should be incorporated into the prefatory sections of any reports <strong>and</strong>/or presentations<br />

that use <strong>AAUDE</strong> data.<br />

Note: <strong>Data</strong> may be shared at a finer level of detail with the highest ranks of university<br />

administration, as these officials are presumed to underst<strong>and</strong> confidentiality policies <strong>and</strong> be<br />

able to honor <strong>AAUDE</strong> restrictions. As the composition of the audience becomes less secure<br />

<strong>and</strong>/or the risk of confidential information increases, the rules on permissible data<br />

presentation should be tightened (e.g., requiring the aggregation of data from a minimum<br />

number of peer institutions). The following table shows guidelines for acceptable use by<br />

audience.<br />

<strong>Guidelines</strong> for Acceptable Uses of Analysis <strong>and</strong> Summaries of <strong>AAUDE</strong> <strong>Data</strong> by Audience<br />

A. Board of Trustees B. Governance<br />

<strong>and</strong> Senior Campus Groups <strong>and</strong> Other<br />

Use of Analysis <strong>and</strong> Summary <strong>Data</strong><br />

Officers<br />

Campus Officers<br />

1. Institution's own data Institutional decision<br />

2. <strong>Data</strong> aggregated within groupings<br />

of at least three institutions <strong>and</strong><br />

institutions are not identified in the<br />

analysis/presentation<br />

3. <strong>Data</strong> aggregated within a peer<br />

grouping of at least three<br />

institutions <strong>and</strong> the institutions are<br />

identified in the analysis<br />

4. <strong>Data</strong> from specific institutions that<br />

are either not identified or their<br />

identities are masked in the<br />

analysis-specific data from<br />

unidentified or masked institutions<br />

5. <strong>Data</strong> from institutions that are<br />

identified in the<br />

analysis/presentation<br />

Agreement that presentation use is acceptable.<br />

Agreement that presentation use is acceptable,<br />

but distribution of hard copy should be done<br />

with extreme caution<br />

Use with extreme caution<br />

4. Confidential Exchange Items with Special <strong>Rules</strong><br />

4<br />

C. Campus-at-large<br />

or Public<br />

Generally<br />

unacceptable.<br />

Consult caretaker or<br />

Coordinator<br />

Not acceptable in<br />

any circumstances<br />

Some <strong>AAUDE</strong> exchange items contain such sensitive <strong>and</strong>/or confidential data that they require<br />

special rules to govern their dissemination. The confidential exchange items with special rules<br />

are listed in the attachment to this report.*


The guidelines <strong>and</strong> rules listed under Category 3 above also apply to the exchange items in this<br />

category (i.e., Category 4). In addition, each exchange item in this category has special rules that<br />

must be observed. The webpage of each of these exchange items should be consulted for the<br />

specific guidelines <strong>and</strong> rules that govern the use <strong>and</strong> dissemination of data from that exchange<br />

item.<br />

Special rules are proposed by the caretaker of an exchange item, assisted by a working group<br />

established to develop those rules. The <strong>AAUDE</strong> Council then approves the special rules <strong>and</strong><br />

posts them on the webpage of the exchange item.<br />

* This statement will eventually be replaced by the web address of the page where the exchange<br />

items are listed.<br />

GT<br />

03/30/2009<br />

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ATTACHMENT<br />

Categories of Exchange Items by Level of <strong>Confidentiality</strong><br />

1. Publicly Reported <strong>Data</strong><br />

� AAUP Faculty Salaries<br />

� IPEDS Fall Enrollment<br />

� IPEDS Completions<br />

� IPEDS Human Resources<br />

� IPEDS Institutional Characteristics<br />

� IPEDS Finance<br />

� NSF R&D Expenditures<br />

� NSF Obligations<br />

� Tuition <strong>and</strong> Required Fees<br />

� NSF Graduate Student Support<br />

� Honors <strong>and</strong> Awards<br />

� Annual Financial Report, Organization Charts, <strong>and</strong> Fact Books<br />

2. Ad Hoc/Special Requests<br />

3. Confidential Exchange Items<br />

� Faculty Profile by CIP<br />

� CUPA Administrative Salaries<br />

� <strong>AAUDE</strong> Enrollment by Program<br />

� Delaware Teaching Load <strong>and</strong> Cost Survey<br />

� Graduate Assistant Stipends<br />

� First-time Freshman Profile<br />

� Undergraduate Time-to-Degree<br />

� CSRDE Graduation <strong>and</strong> Retention Rates<br />

� Current Developments Survey<br />

4. Confidential Exchange Items with Special <strong>Rules</strong><br />

� Faculty Salaries by CIP Code<br />

� <strong>AAUDE</strong> Survey of Faculty Benefits<br />

� Faculty Surveys<br />

� Graduating Senior Survey<br />

� Graduate Student Surveys<br />

� National Survey of Student Engagement<br />

� Alumni Surveys<br />

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